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SEAS SHIPPING COMPANY, INC. v. COMMISSIONER

Docket No. 3105-62.

24 T.C.M. 1222 (1965)

T.C. Memo. 1965-240

Seas Shipping Company, Inc. v. Commissioner.

United States Tax Court.

Filed August 31, 1965.

Attorney(s) appearing for the Case

Richard H. Appert, 14 Wall St., New York, N. Y., and David Sachs, for the petitioner. George T. Rita, for the respondent.

Memorandum Findings of Fact and Opinion

HOYT, Judge:

Respondent has determined a deficiency in petitioner's income tax for the calendar year 1957 in the amount of $1,476,539.74.

The issues for decision are:

(1) What was the fair market value, for purposes of computing the correct amount of gain on sale, of a block of 300,000 shares of Moore-McCormack Lines, Inc., stock received by petitioner as part of the consideration

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